Memorandum submitted by Campaign to Protect
Rural England (CPRE)
INTRODUCTION
1. The Campaign to Protect Rural England
(CPRE) welcomes the Environmental Audit Committee's inquiry into
progress since publication of its report Housing: Building
a Sustainable Future in January 2005; we are pleased to have
the opportunity to make a submission.
2. CPRE advocates positive solutions for
the long-term future of the countryside and the sustainable use
of land and other natural resources in both town and country.
Founded in 1926, we have decades of experience of the operation
of the spatial planning system in England and are the single largest
third party participant in it. Our volunteers engage with the
preparation and review of development plans at regional, county
and local levels, and scrutinise over 100,000 planning applications
annually. CPRE played a leading role in arguing for the changes
to planning policy embodied in PPG3 Housing (2000) and
has campaigned since for its implementation. We believe that the
planning system should:
— enable society to meet identified
needs for housing;
— foster the regeneration and renewal
of existing urban areas in preference to greenfield expansion;
— respect the capacity of the environment
to accommodate development, in line with the UK Sustainable Development
Strategy's emphasis on environmental limits and mindful of the
probable implications of climate change; and
— require high standards of design,
accessibility and green construction and operation.
THE GOVERNMENT'S
APPROACH
3. CPRE has major concerns about the Government's
approach to housing. We do not believe that the recent pronouncements,
including the Five Year Plan Sustainable Communities: Homes
for All (January 2005) and the consultation paper Planning
for Housing Provision (July 2005), adequately address the
environmental impact of the scale of housing development envisaged
in the Sustainable Communities Plan and subsequently in Kate Barker's
Review of Housing Supply. Nor, in our view, has the Government
yet satisfactorily responded to the concerns and questions set
out by the Committee in its report in January. In particular,
there is little evidence that the Government has addressed effectively
the Committee's first recommendation, that "the environmental
impacts of the proposed increase in housebuilding deserve much
greater consideration than they have yet received from the Government".
Sustainable Communities: Homes for All
4. The extension of the Density Direction
to include the South West and East of England, announced in the
Five-Year Plan, is welcome if long overdue. Nonetheless, the minimum
density of 30 dwellings per hectare required in PPG3 is insufficient
to enable a viable bus service, for example, and represents very
wasteful use of land. Raising density per se will do little
to improve the environmental impact of new development unless
environmental capacity, location, sustainable construction, mix
of uses, layout and design are also fully incorporated into the
planning process. The Green Belt Direction, prefigured in the
Plan, will by the ODPM's own admission do very little to strengthen
protection of Green Belt land from inappropriate development.
Moreover, the proposal is overshadowed by the large-scale threats
to Green Belt land arising directly from Government policy, notably
the recent approval of large-scale housing development west of
Stevenage in Hertfordshire, the proposals for airport expansion
set out in the Air Transport White Paper and proposed growth areas
in Cambridgeshire, Bedfordshire, Buckinghamshire, Essex and Hertfordshire.
Planning for Housing Provision
5. CPRE is very concerned by the proposed
approach to planning for housing set out in the consultation paper
Planning for Housing Provision (ODPM, July 2005). While
we welcome the increased emphasis placed on establishing a sound
evidence base to inform planning policies and decisions, we believe
the proposed approach to allocating land would:
— lead to more housebuilding in areas
where there is already high demand and the countryside is under
the greatest pressure from development;
— reduce the impetus and viability
of urban regeneration, further blighting areas of low demand;
— undermine the sequential approach
in PPG3 and progress made on recycling brownfield land for housing;
— make it harder to meet UK commitments
on sustainable development, eg to reduce greenhouse gas emissions,
by encouraging unsustainable patterns of development;
— undermine the plan-led system and
locally accountable decision-making;
— widen regional disparities by encouraging
more development in areas of high demand and discouraging it in
areas where the market is weak;
— fail to meet the need for affordable
housing; and
— not address the key issue of housebuilders
who have landbanks with planning permission but are reluctant
to bring it forward for development.
6. The proposals in Planning for Housing
Provision appear not to have taken proper account of environmental
factors or indeed of the Government's own sustainable development
objectives as set out in the revised UK Sustainable Development
Strategy and PPS1 Delivering Sustainable Development (2005).
In its initial acceptance of Kate Barker's report, the Government
stated that more consideration was needed of the implications
for the environment and sustainability more widely of the proposed
increase in housebuilding—something Barker herself acknowledged.
It is disturbing, therefore, that the findings of the research
into these effects, subsequently commissioned by the Government
and led by Entec, have yet to be published. Further, we understand
that they were not available to inform the proposals in the consultation
paper.
7. CPRE has commissioned its own independent
research to assess the implications of the proposals for urban
regeneration, the environment and housing affordability (a copy
of the report Will They Work? is enclosed). This focussed
on selected areas where the ratio of house prices to income is
among the highest, and therefore the increase in housebuilding
aimed at reducing prices (as suggested by Barker) might be expected
to be greatest. The research found that senior local authority
planners believed the proposals would:
— result in more development on greenfield
(and in some cases Green Belt) sites;
— make it harder to follow the sequential
approach to site allocation and release set out in PPG3;
— have little direct effect on the
availability of affordable housing;
— severely prejudice the prospects
for successful urban renewal; and
— make it harder for planning to achieve
sustainable development.
THE SUSTAINABLE
COMMUNITIES PLAN
8. Since its publication in 2003, CPRE has
maintained a close interest and involvement in the Sustainable
Communities Plan and its implementation. We have so far been disappointed
that the environmental sustainability of the Sustainable Communities
Plan, and in particular the growth areas it proposes, appears
highly questionable. The gestation of the draft East of England
Plan (Regional Spatial Strategy 14), in which CPRE is a key participant,
illustrates these concerns.
9. We note that in their submissions to
the examination-in-public of the draft Plan, the Government's
own agencies (English Nature and the Countryside Agency) have
jointly expressed serious concern at the "absence of evidence
that the in the Plan to demonstrate that the proposed level of
growth can be accommodated without compromising core environmental
concerns". This underlines the points, made in the independent
Sustainability Appraisal of the draft Plan, that "further
development on any significant scale is likely to have serious
negative impacts on water resources, biodiversity, tranquillity,
air quality, recreational access and congestion", and that
"the rate and intensity of economic, housing and infrastructure
growth envisaged for the region . . . is intrinsically damaging
to many aspects of the environment and quality of life".[11]
10. The agencies refer to their concerns
about the "apparent lack of sustainability appraisal of the
Sustainable Communities Plan", one of the "key drivers"
of draft RSS14, which have "fundamentally determined the
scale of growth proposed". "If", they continue,
"the principles of sustainable development in the widest
sense have not been applied to these key drivers, then the probability
of the RSS being inherently sustainable in its influence must
be seriously weakened".[12]
Yet the ODPM has explicitly stated, in its opening statement to
the examination-in-public of the draft Plan, that "any future
increase in housing supply will be delivered within the principles
of the Sustainable Communities Plan",[13]
with no mention of the Sustainable Development Strategy, PPS1
or any other environmental or sustainability policy.
11. The agencies further point out that,
if the draft RSS is not sustainable, this would be contrary to
the statutory purpose of the planning system as laid down in Section
39 of the Planning and Compulsory Purchase Act 2004.
12. The failure of the Government to subject
the Sustainable Communities Plan to any form of public consultation
or environmental appraisal appears to be at the root of many of
the unsustainable pressures the environment faces from development.
The failure of the East of England Regional Assembly to make any
changes to the submission draft of RSS14 in the light of the Sustainability
Appraisal highlights deficiencies encountered so far in the application
of the Strategic Environmental Assessment Directive, which came
into force in July 2004. We understand that the European Commission
will report to the European Parliament in 2006 on member states'
progress with implementation of the SEA Directive. In the light
of the recent ruling by the European Court of Justice on the UK
Government's failure correctly to apply the Habitats Directive
(92/43/EEC) it will be interesting to see what assessment is made
of its performance so far on the SEA Directive.
THE CODE
FOR SUSTAINABLE
BUILDINGS
13. CPRE welcomes moves to encourage better
standards of efficiency in the use of materials and resources
in construction. These are long overdue. We believe it is important
that these should be mandatory and extend well beyond energy and
water efficiency in construction and use to the sourcing of materials,
particularly the re-use and recycling of aggregates and other
building materials. The new spatial approach to planning, embodied
by the 2004 Act and national planning policy in PPS1, PPS11 and
PPS12, presents an opportunity to make these elements key aspects
of the initial strategic stage of planning rather than bolted
on at the end. Early consideration of natural resource demands
should enable planners to select options that minimise the demand
for materials that development policies and proposals will give
rise to later on, thus helping to minimise the wider environmental
footprint of development.
14. The EcoHomes methodology, developed
by BRE, provides a holistic representation of the environmental
effects of housing construction. These include energy, water,
construction materials, waste, land use (ie greenfield site or
previously developed land), transport and wildlife. The methodology
proposes standards to manage this range of effects. We hope that
the Code will strengthen this methodology, retain its full integrity
and make its application mandatory across the country.
15. The Government has made clear its intention
to rely overwhelmingly on private developers to provide housing.
It is therefore inexplicable that it appears determined to make
the Code purely voluntary for private developers. We do not believe
that a voluntary code is remotely adequate to the task facing
us. The Code is not expected to cover refurbishment. The challenge
of retrofitting energy and water-efficiency measures to existing
housing is enormous on its own without allowing developers to
continue to add unsustainable buildings to the total housing stock.
16. We are also concerned by reports that,
having resisted efforts to draft more demanding building regulations,
the ODPM may seek lower standards in the Code. In the absence
of a mandatory code with demanding standards, the only way to
raise standards among private housing developers would be through
strong development plan policies. Yet, the legality of addressing
these issues through plan policies is to our knowledge untested,
and its acceptability to Government is called into question by
paragraph 30 of PPS1, which states:
"Planning policies should not replicate,
cut across, or detrimentally affect matters within the scope of
other legislative requirements, such as those set out in Building
Regulations for energy efficiency."
17. Even if such objections could be overcome,
this approach would impose a much greater time and cost burden
on the public by demanding that the same arguments be had repeatedly
through individual local Development Plan Document reviews. It
would also reduce certainty for developers working on more than
one local authority area, and potentially encourage competition
among local planning authorities for the lowest standards (which
would therefore be the most attractive to developers).
18. There is a danger that sustainable construction
standards in new development may be used to ignore the wider environmental
dimensions of housing policy. It is important to remember that
even a mandatory code will not stop development which is in the
wrong place from inflicting extensive environmental harm. A major
concern about the Sustainable Communities Plan growth areas is
the huge increase in road traffic—and consequent noise,
light and air pollution and emissions—that will arise from
development on the scale and in the places proposed. The emphasis
on housing rather than mixed use development and the inability
of planners and developers to ensure provision of excellent public
transport in the growth areas appears to make this inevitable.
Further, since newly built housing represents only 1% of total
stock at any one time, its contribution to overall sustainability
objectives in the medium term is tiny, albeit cumulatively important.
WATER
19. Concern about water supply does not
appear to be a "knee-jerk reaction to a few hot, dry summers".
Combined with the forecast effects of climate change on rainfall
and flooding, it is an acute and growing concern. The Chartered
Institution of Water and Environmental Management (CIWEM) is so
concerned that it has called for a rethink and public audit of
the Government's growth plans.
20. Concern is most acute in the East of
England. This is the driest region in Britain, where a combination
of wetter winters, even drier summers, extensive low-lying land
and vulnerable coasts raises serious questions as to the wisdom
and practicality of the "step-change" in development
proposed in the Sustainable Communities Plan and now taken forward
in the draft East of England Plan. In evidence to the examination-in-public
of the draft Plan, the Environment Agency has stated that the
growth proposals demand two large and expensive expansions in
supply capacity as well as a 15% improvement in water efficiency
in all new housing and an average 8% reduction in water use in
all existing housing across the region. Such a proposition, simply
to accommodate the level of growth proposed in the next 16 years,
is a formidable challenge, and there must be doubts as to its
achievability. It also poses unanswered questions about the polices
driving the growth.
21. The obligation on water companies to
supply water to new development has made it far too easy for planners
and politicians to ignore the problem of water supply. While education
of users in efficiency should help, relying on intended, voluntary
behavioural change to ensure the sustainability of planned growth
appears unwise. Large-scale expansion of water supply capacity
(ie new reservoirs and increased abstraction) also has major environmental
effects. Alternatives, such as desalination plants or some sort
of water grid, need large quantities of energy to function, which
raises its own sustainability questions. Changes to water pricing,
combined with conservation measures and calibrated to minimise
the risk of individual households suffering water poverty, but
designed to penalise lavish use, are likely to be necessary. The
forthcoming Code for Sustainable Buildings should set high, mandatory,
water efficiency standards so that what is built now is resilient
to increasing scarcity and much higher prices in future. Above
all, greater attention to the capacity of the environment to accommodate
and support new development is essential to addressing the issue
of water supply. CPRE believes that the best way of giving water
the prominence it deserves in spatial in planning is for there
to be a new Planning Policy Statement on water issues.
RECOMMENDATIONS
22. CPRE believes that a number of essential
challenges have been ignored by the Government's emerging policy
on housing. For them to be adequately addressed, we believe the
following measures are needed:
— Review of Public Service Agreements
relating to regional development through the Comprehensive Spending
Review to create a coherent national context within which regional
policy which respects environmental capacity considerations can
be developed and applied.
— Proper and rigorous application of
Strategic Environmental Assessment to all development plans, including
Regional Spatial Strategies. This should include full assessment
of a range of options and their natural resource implications,
and revision of draft policies and proposals in the light of findings
as they emerge.
— Strong reiteration of the emphasis
on urban regeneration and the sequential approach to development
in draft PPS3, combined with complementary fiscal incentives,
notably reduction of VAT on renovation and repair.
— Recognition that any measures to
secure funding for infrastructure costs to support development
should not further increase the attractiveness and viability of
greenfield over brownfield sites for developers or local authorities
(or the communities the latter represent).
— Publication of a new Planning Policy
Statement (PPS) on water.
— Introduction of a mandatory Code
for Sustainable Buildings, applicable to all new development (with
possible exemptions for Listed Buildings). This should strengthen
the EcoHomes methodology, retaining its full integrity, and set
demanding standards that are robust enough to accommodate the
expected effects of climate change over the next several decades.
— Introduction of complementary fiscal,
policy and other measures to boost retrofitting of water and energy-efficiency
measures and micro-renewable energy generation capacity to the
existing housing stock.
November 2005
11 East of England Plan: Sustainability Appraisal
Report Levett-Therivel/Land Use Consultants/EERA, November
2004, pages 59 and 62. Back
12
Matter 1A, joint submission by English Nature and the Countryside
Agency to the examination-in-public of the draft East of England
Plan. Back
13
East of England Public Examination-Opening Statement by ODPM on
growth issues, November 2005. Back
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